JEWELEX INDIA PRIAVTE LIMITED,MUMBAI vs. DCIT CIRCLE-14(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarjewelex India Private V/S. Deputy Commissioner Of Limited बनाम Income Tax, Circle – 401 Trade Centre, Bandra 14(1)(1), Aayakar Bhavan, Kurla Complex, Bandra Maharishi Karve Marg, (East), Mumbai – 400 098, Mumbai – 400 020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcj4523H Appellant/अपीलार्थी .. Respondent/प्रतिवादी

80G out of CSR expenses are in accordance with the decisions of various benches of Tribunal. Thus, the view taken by assessing officer cannot be said to be erroneous. Thus, the pre-requisite twin conditions for exercising jurisdiction under section 263 has not meet out in the present case hence we quash / set aside the order of Pr. CIT dated

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

In the result, appeals of both, revenue and assessee are partly allowed for all the three assessment years

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 80G for CSR expenditure and the same needs to be set aside, and the disallowance made by the Assessing Officer during the course of assessment proceedings be upheld." 16. "Whether on facts and in circumstances of the case and in law, the Ld. CIT(A) erred by allowing the claim of gratuity expenses amounting to 200.41 crores. The additional

RELIANCE INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE-3(4), MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Transfer pricing adjustment that was confirmed by Ld CIT(A). APPEALS OF THE REVENUE:- 15. We shall now take up the appeals filed by the revenue for AY 2017-18 and 2018-19. Various issues urged by the revenue are summarized below:- (A) COMMON ISSUES URGED BY THE REVENUE IN BOTH THE YEARS:- a) Reduction of claim of depreciation

DCIT- 3(4) , MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Transfer pricing adjustment that was confirmed by Ld CIT(A). APPEALS OF THE REVENUE:- 15. We shall now take up the appeals filed by the revenue for AY 2017-18 and 2018-19. Various issues urged by the revenue are summarized below:- (A) COMMON ISSUES URGED BY THE REVENUE IN BOTH THE YEARS:- a) Reduction of claim of depreciation

RELIANCE INDUSTRIES LTD.,MUMBAI vs. ACIT CIRCLE 3(4), MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Transfer pricing adjustment that was confirmed by Ld CIT(A). APPEALS OF THE REVENUE:- 15. We shall now take up the appeals filed by the revenue for AY 2017-18 and 2018-19. Various issues urged by the revenue are summarized below:- (A) COMMON ISSUES URGED BY THE REVENUE IN BOTH THE YEARS:- a) Reduction of claim of depreciation

DCIT-3(4), MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Transfer pricing adjustment that was confirmed by Ld CIT(A). APPEALS OF THE REVENUE:- 15. We shall now take up the appeals filed by the revenue for AY 2017-18 and 2018-19. Various issues urged by the revenue are summarized below:- (A) COMMON ISSUES URGED BY THE REVENUE IN BOTH THE YEARS:- a) Reduction of claim of depreciation

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. RELIANCE RETAIL LIMITED, MUMBAI

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Transfer Pricing Officer under section 92CA of the Act on 16.07.202, who passed an order dated 27.01.2022 without proposing any adjustment to the arm’s length price. 3. The assessment was completed under section 143(3) read with section 144B of the Act vide order dated 27.09.2022. During following additions and disallowances: i. Disallowance of deduction under section 80G

ACIT, CIRCLE - 3 3 1, MUMBAI vs. JAMNAGAR UTILITIES AND POWER PVT LTD, MUMBAI

In the result, both the appeals of the Revenue are allowed\npartly

price to NIL arbitrarily and MTM loss arising out of\nrevaluation/fair value adjustment is not applicable as\nthere is no market?\"\n6. \"Whether on the facts and in the circumstances of the case and in\nlaw, the Ld.CIT(A) has justified in deleting the addition of fair value\nadjustment on asset being redeemable preference shares(RPS) in\nbook profit, without

ACIT, CIRCLE - 3 3 1, MUMBAI vs. JAMNAGAR UTILITIES AND POWER PVT LTD, MUMBAI

In the result, both the appeals of the Revenue are allowed\npartly

price to NIL arbitrarily and MTM loss arising out of\nrevaluation/fair value adjustment is not applicable as\nthere is no market?\"\n6. \"Whether on the facts and in the circumstances of the case and in\nlaw, the Ld.CIT(A) has justified in deleting the addition of fair value\nadjustment on asset being redeemable preference shares(RPS) in\nbook profit, without

ABM KNOWLEDGEWARE LIMITED,MUMBAI vs. ASSESSING OFFICER CIRCLE 4(1)(1), MUMBAI

In the result, the appeal filed by the assessee stands partly\nallowed

Transfer Pricing\nOfficer, as the case may be, shall be deemed to be erroneous in so far as\nit is prejudicial to the interests of the revenue, if, in the opinion of the\nPrincipal Chief Commissioner or Chief Commissioner or Principal\nCommissioner or Commissioner,—\n(a) the order is passed without making inquiries or verification which\nshould have been made

B. ARUNKUMAR CAPITAL & CREDIT SERVICES PVT LTD ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX 3, MUMBAI

In the result the appeal filed by the assessee stands partly\nallowed

Transfer Pricing\nOfficer, as the case may be, shall be deemed to be erroneous in so far\nas it is prejudicial to the interests of the revenue, if, in the opinion of the\nPrincipal Chief Commissioner or Chief Commissioner or Principal\nCommissioner or Commissioner,—\n(a) the order is passed without making inquiries or verification which\nshould have been made

PASHUPATI CAPITAL SERVICES PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX OFFICER, MUMBAI - 4, MUMBAI

In the result, appeal filed by the assessee is allowed in above\nterms

80G of\nthe Act. Hence the assessment order suffers from lack of enquiry and\nExplanation 2 of section 263 of the Act is attracted in the case of the\nassessee and the jurisdiction of section 263 of the Act has been rightly\nexercised by the Ld. PCIT.\n12. In order to appreciate the arguments advanced by the parties, we\ndeem

RELIANCE RETAIL LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 8(1)(1), MUMBAI

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Transfer Pricing Officer. On merits, the CIT(A) granted relief to the assessee on the issues relating to deduction under section 80JJAA, disallowance under section 14A, treatment of AJIO marketing expenditure and addition on account of creditors written back. The disallowance under section 80G

TATA MOTORS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.631/मुं/2013 (िन.व. 2008-09) Tata Motors Limited Bombay House, 24,Homi Mody Street, Hutama Chowk, Mumbai – 400001. Pan: Aaact-2727-Q ...... अपीलाथ"/Appellant बनाम Vs. The Addl. Commissioner Of Income Tax Circle -2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri J.D.Mistry, Sr.Advocate With Shri Nikhil Tiwari,Advocate "ितवादी "ारा/Respondent By : Ms. Vatsala Jha, Cit-Dr & Shri Manoj Kumar Singh, Sr.Ar सुनवाई की ितिथ/ Date Of Hearing : 10/11/2023 घोषणा की ितिथ/ Date Of Pronouncement : 05/02/2024 आदेश/Order Per Vikas Awasthy, Jm:

Pricing. The name of Shri Vatsalya Saxena figures in the list of ‘Officers who are being posted to other station/region’ at Sl.No.11. Thus, he was transferred in the charge of Director General of Income Tax (International Taxation) by the Board and the DGIT(IT) posted Shri Vatsalya Saxena vide office order dated 05/04/2011 as TPOII(2). Thus posting orders

M/S PIRAMAL ENTERPRISES LIMIITED ,MUMBSI vs. DY CIT(APPEAL)-RANGE-8(2)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2017-18 M/S Piramal Enterprises Ltd., Dy. Cit, Mumbai-8(1)(2), Or Piramal Tower, Agastya National Facelss Assessment Vs. Corporate Park, Lbs Marg, Centre, Delhi, Kamani Junction, Kurla Room No. 624, 6Th Floor, (West), Aayakar Bhavan, M.K. Road, Mumbai-400070. Mumbai-400020. Pan No. Aaacn 4538 P Appellant Respondent : Assessee By Mr. Ronak Doshi : Revenue By Mr. Rakesh Ranjan, Cit-Dr & Mr. Samuel Pitta, Dr : Date Of Hearing 17/11/2022 : Date Of Pronouncement 28/12/2022

80G of the Act. M/s Piramal Enterprises Ltd. 7 WITHOUT PREJUDICE TO GROUND I, WITHOUT PREJUDICE TO GROUND I, II, III AND VI AS II, III AND VI AS MENTIONED ABOVE: MENTIONED ABOVE: GROUND NO. VIII: DEDUCTION UNDER SECTION SOGGB GROUND NO. VIII: DEDUCTION UNDER SECTION SOGGB GROUND NO. VIII: DEDUCTION UNDER SECTION SOGGB

WNS GLOBAL SERVICES PRIVATE LIMITED,MUMBAI vs. ASESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, NEW DELHI, NEW DELHI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarwns Global Services Private Vs Assessment Unit, National Faceless Limited, Mumbai Assessment Centre, New Delhi Pl-10/11, Gate No.4, Godrej- Boyce Complex, Pirojshanagar, L.B.S.Marg, Vikhroli (West), Mumbai-400 079 Pan: Aaacw2598L Appellant Respondent

transfer pricing adjustment under section 92CA amounting to Rs.11,26,24,233/-. In addition, disallowances were made as follows: Disallowance under section 80G

ASST CIT CIR 4(3)(2), MUMBAI vs. MORGAN STANLEY INDIA CO.P.LTD, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Co No. 145/Mum/2016 (Arising In Ita No. 1794/Mum/2016 For A.Y. 11-12)

transfer pricing adjustment of ₹17,34,561/- and disallowance under Section 14A CO No.145/Mum/2016 ITA No.1794 & 1715/Mum/2016 Morgan Stanley India Company P. Ltd.; A.Y. 11-12 of the Act of ₹1,70,70,056/- was made and total income was assessed at ₹330,57,25,166/-. 010. Both the parties are aggrieved with the above order and therefore

MORGAN STANLEY INDIA COMPANY P. LTD,MUMBAI vs. ASST CIT RG 4(3)(2), MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Co No. 145/Mum/2016 (Arising In Ita No. 1794/Mum/2016 For A.Y. 11-12)

transfer pricing adjustment of ₹17,34,561/- and disallowance under Section 14A CO No.145/Mum/2016 ITA No.1794 & 1715/Mum/2016 Morgan Stanley India Company P. Ltd.; A.Y. 11-12 of the Act of ₹1,70,70,056/- was made and total income was assessed at ₹330,57,25,166/-. 010. Both the parties are aggrieved with the above order and therefore